- 11 - On the limited evidence before us (including petitioners' and American Silver's written contemporaneous representations as to the value of the jewelry, the evidence reflected on Al Zuni's tax returns as to the cost of the jewelry inventory that Khalaf purchased for Al Zuni in 1990, 1991, and 1992 in the $1 million plus range and regarding the cost of the jewelry inventory Al Zuni had on hand at yearend 1990 and 1991 in the one-half million dollar range), we conclude that the value of the jewelry inventory transferred to Khalaf on September 15, 1992, was $671,413. With regard to Al Zuni’s cost basis in the jewelry inventory transferred to Khalaf on September 15, 1992, the parties stipulated that the jewelry inventory had a cost basis to Al Zuni of $538,000. Subtracting the $538,000 cost from the $671,413 value of the jewelry inventory transferred from Al Zuni to Khalaf produces income to Al Zuni of $133,413. Petitioners contend that certain checks totaling $133,000 written during 1992 by Khalaf on Al Zuni’s bank account in favor of Khalaf, Khalaf’s daughter and son, and cash should be treated as additional purchases of jewelry on behalf of Al Zuni, and should be treated as increasing Al Zuni’s cost basis in the jewelry inventory by at least $133,000 and as eliminating essentially all gain on the transfer of the jewelry inventory to Khalaf. No credible evidence indicates that these checks constitute purchases of jewelry inventory. Petitioners' attemptPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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